Internal Revenue Bulletin:
2011-51

December 19, 2011

Introduction

The Internal Revenue Bulletin is the authoritative instrument
of the Commissioner of Internal Revenue for announcing official rulings
and procedures of the Internal Revenue Service and for publishing
Treasury Decisions, Executive Orders, Tax Conventions, legislation,
court decisions, and other items of general interest. It is published
weekly and may be obtained from the Superintendent of Documents on
a subscription basis. Bulletin contents are compiled semiannually
into Cumulative Bulletins, which are sold on a single-copy basis.

It is the policy of the Service to publish in the Bulletin all
substantive rulings necessary to promote a uniform application of
the tax laws, including all rulings that supersede, revoke, modify,
or amend any of those previously published in the Bulletin. All published
rulings apply retroactively unless otherwise indicated. Procedures
relating solely to matters of internal management are not published;
however, statements of internal practices and procedures that affect
the rights and duties of taxpayers are published.

Revenue rulings represent the conclusions of the Service on
the application of the law to the pivotal facts stated in the revenue
ruling. In those based on positions taken in rulings to taxpayers
or technical advice to Service field offices, identifying details
and information of a confidential nature are deleted to prevent unwarranted
invasions of privacy and to comply with statutory requirements.

Rulings and procedures reported in the Bulletin do not have
the force and effect of Treasury Department Regulations, but they
may be used as precedents. Unpublished rulings will not be relied
on, used, or cited as precedents by Service personnel in the disposition
of other cases. In applying published rulings and procedures, the
effect of subsequent legislation, regulations, court decisions, rulings,
and procedures must be considered, and Service personnel and others
concerned are cautioned against reaching the same conclusions in other
cases unless the facts and circumstances are substantially the same.

The Bulletin is divided into four parts as follows:

Part I.—1986 Code. This
part includes rulings and decisions based on provisions of the Internal
Revenue Code of 1986.

Part II.—Treaties and Tax Legislation. This part is divided into two subparts as follows: Subpart A, Tax
Conventions and Other Related Items, and Subpart B, Legislation and
Related Committee Reports.

Part III.—Administrative, Procedural,
and Miscellaneous. To the extent practicable, pertinent
cross references to these subjects are contained in the other Parts
and Subparts. Also included in this part are Bank Secrecy Act Administrative
Rulings. Bank Secrecy Act Administrative Rulings are issued by the
Department of the Treasury’s Office of the Assistant Secretary
(Enforcement).

Part IV.—Items of General Interest. This part includes notices of proposed rulemakings, disbarment and
suspension lists, and announcements.

The last Bulletin for each month includes a cumulative index
for the matters published during the preceding months. These monthly
indexes are cumulated on a semiannual basis, and are published in
the last Bulletin of each semiannual period.